GENERAL COMMENTS
Overarching comment regarding the action plan
The Draft Waste Action Plan is frustratingly incomplete and contradictory, containing a number of groundbreaking commitments e.g. waste reduction and diversion targets, a container refund scheme and a statewide landfill levy while also missing many of the elements fundamental to an effective plan e.g. lacking over-all goals and objectives, failing to address roles and responsibilities, postponing decisions on governance structures, not making any specific commitments on infrastructure and omitting many policy and legislative reforms that industry and the community are demanding.
Given there are a number of specific strategies and plans proposed to be done in the next few years, the TCT recommends that it would be beneficial to revise the waste action plan when those supplementary plans and strategies are completed to create a comprehensive, coherent and effective action plan for waste management. We would prefer for those plans and strategies to be brought forward to the end of 2020 with a deadline of early 2021 for the completion of a revised waste action plan.
Provide a clearer picture of Tasmania’s waste management performance and challenges
The Draft Waste Action Plan should have included an introductory chapter providing an overview of the major types of wastes generated in Tasmania, identify the major problem wastes, a comparison of the diversion rates of the three major sectors and how these compare with other states. This information is readily available (see references in the next section) and should help set the priorities of the action plan. This would have set the background for establishing the priorities.
Critical need to address industrial waste
In October 2013 consultants Blue Environment were commissioned by the Tasmanian Waste Management Advisory Committee to investigate current waste management practices and explore opportunities and barriers for more effective management of five priority waste streams.
It is notable that the report found that of all industrial waste ‘Tasmania’s recovery rate is significantly lower than other states’. In the report industrial waste refers to construction and demolition and commercial and industrial wastes. Over 345,000 tonnes of industrial waste was generated in Tasmania in 2010-11, of which 73% went to landfill. Most states achieved a diversion rate more than twice as large. The report found ‘The recovery rate for construction and demolition waste is reportedly negligible’ (page 13).
The March 2017 report to Local Government Association of Tasmania ‘LGAT Waste and Resource Management Strategy’ by MRA Consulting Group found that in 2012-13 the overall diversion rate from landfill in Tasmania was 37%, half the rate of ACT, Victoria, New south Wales and South Australia. Diversion of construction and demolition waste was 9%, commercial and industrial waste 40% and municipal solid waste 39%. Critically the report found that the ‘The difference in diversion rates is most significant from industrial sources, i.e. commercial and industrial and construction and demolition’ (page 5). The report provided a series of recommendations for addressing this deficiency that should have been adopted in the Draft Waste Action Plan. At the least, the relative failure of diversion in industrial sectors should have been acknowledged in the Draft Waste Action Plan as requiring special attention.
We note that the Draft Waste Action Plan states that ‘The Tasmanian diversion rate in 2016-17 was 49% compared to the national average of 58%’, referencing this figure to the National Waste Report for 2018. We find it difficult to believe the diversion rate in Tasmania increased from 37% to 49% in a matter of four years and perhaps the difference is due to different methodologies. If however, there has been a rapid increase in diversion it should be prominently identified and explained in the final action plan.
Lack of goals and objectives
The Draft Waste Action Plan lacks clearly articulated goals and objectives. While there are targets for waste reduction and diversion from landfill each chapter and action should contain goals and objectives.
Goals should include employment in the waste management sector, carbon emissions reduction, protection of the environment and human health, as well as waste reduction and recovery.
It is a major omission to not include protection of the environment and human health as clear goals of the action plan. We note that the 2017 MRA consulting Group’s report to LGAT dedicated an entire chapter to the protection of the environment and human health and the final waste action plan should do likewise.
Inconsistency in referring to reducing and recycling
Throughout the Draft Waste Action Plan there are references to avoiding or reducing waste is a priority over recycling but this is inconsistent. There are many instances where recycling is referred to alone. There should be a consistent reference to the waste management hierarchy in the final action plan.
Response to the recycling crisis in southern Tasmania
We note the Draft Waste Action Plan was released just at the time that SKM Recycling was put into administration, leading to some recyclables that were being collected from southern Tasmania being stockpiled at SKM’s facility at Derwent Park. SKM was shut down by the Victorian EPA due mainly to its inability to profitably recycle some materials leading to stockpiling in excess of regulatory limits. It has now come to light that for at least the first half of 2019 all plastics and possibly other materials collected from southern Tasmania and sent to SKM’s facilities in Victoria were being stockpiled and have now been sent to landfill.
The final waste action plan should include an explanation for this critical break down in recycling services and offer some suggestions for how it is to be avoided in the future. The failure of SKM Recycling demonstrates the need for regular monitoring and reporting of recycling companies, critically to inform councils and rate-payers whether the materials they put into their recycling bins are being recycled.
No review of the previous strategy
We note that there was no review undertaken of the previous Waste Management Strategy for Tasmania 2009 and this is a missed opportunity to learn from the strengths and weaknesses of this strategy.
SPECIFIC COMMENTS ON THE DRAFT WASTE ACTION PLAN
The Draft Waste Action Plan and the circular economy
The Draft Waste Action Plan purports to be a plan for starting the transition toward a circular economy but it does not provide a clear explanation of even the most fundamental elements of a circular economy. Section 1 refers to the ‘ReSOLVE’ model but this is only one model and some of the key terms used are not defined e.g. virtualise and exchange. Very brief definitions are provided for other key elements.
In opting for the more recent terminology, ‘Circular Economy’, some of the key waste management principles that are embodied in the circular economy model have been omitted. The 2009 Tasmanian Waste and Resource Management Strategy explained the key principles very well and these definitions should be incorporated into the final waste action plan i.e.
- Waste management hierarchy
- Environmental stewardship
- Precautionary principle
- Life-cycle principle
- User pays and polluter pays
Statewide waste levy
The Draft Waste Action Plan includes a commitment to the introduction of a statewide levy on each tonne of waste sent to landfill by 2021 and that it should replace existing council levies. This is strongly supported. The absence of a waste levy has been the biggest impediment to progressing waste management in Tasmania.
We note that the action plan commits to the wide public consultation on the design and level of the levy. This is strongly supported. However, the TCT recommends that the final action plan should commit to a minimum starting level for the levy (see below). If a waste levy is too low it will not be a disincentive to landfilling of waste and funds raised will largely be used for administration.
It is important that the funds raised by the levy are not frittered away but are redirected by an independent group of experts to projects and businesses to assist with waste reduction, reuse and recycling.
The impact of the levy as a cost signal is briefly mentioned but it is not properly explained. A full explanation along with any empirical evidence from other states should be included in the final action plan. The 2017 MRA Consulting Group report can be used as a guide in respect to this point. Helping to educate the broader community on this vital economic principle is important as the government proceeds with consultation on the design and level of the levy.
We suggest that the landfill levy be initially set at $40 per tonne (which is less than half of the levies in pace in mainland states) and then have it incrementally increase each year to a level equivalent to mainland states. The final plan should commit to a starting level for the levy.
In addition to progressing with a landfill levy, it is critical that the state government ensures that all existing landfill facilities charge gate fees that fully fund the landfill site for its entire life including capping and monitoring.
We note that there are no other financial incentives or sanctions considered (other than a vague reference to a possible loan scheme) and this should be rectified by the final action plan including a commitment to continue to investigate additional measures.
The final action plan should be amended to clarify that Rethink Waste Tasmania has in recent years only operated in the north of Tasmania in part because of the absence of a regional waste management organization in the south.
Container refund scheme
The state government has committed to the introduction of a Container Reuse Scheme by 2022 and the TCT commends the government for this. While we accept the need for at least two years to develop such a scheme, the government should also commit to a timeframe for the release of draft CRS legislation and for tabling a final bill in Parliament.
While the objectives of a CRS are admirable i.e. to reduce litter and generate streams of recyclables, it should be acknowledged that a CRS by its self will not necessarily increase recycling rates. It is vital that the government commits in the final action plan (via the waste levy or other means) to invest into Tasmanian-based recycling industries so we recycle containers returned through the CRS here in Tasmania.
Waste reduction and resource recovery targets
The Draft Waste Action Plan commits to a range of targets for waste reduction and recovery and this commitment to the need for targets is strongly supported. The lack of targets has been long identified as a key reason for Tasmania falling behind other states in landfill diversion and resource recovery rates.
The key commitment is to achieve a 40% average recovery rate from all waste streams by 2025 and 80% by 2030. The final strategy should commit to annual targets to ensure that we don’t get 5 to 6 years down the track and find we have missed the first target by a long way. A range of sanctions and incentives need to be applied to ensure that industries and landfill facilities that do not reach the targets get back on target.
As stated previously in this submission the MRA Consulting Group’s 2017 submission to LGAT found that in 2012-13 in Tasmania 40% of commercial and industrial waste and 39% of municipal solid waste was being diverted from landfill in 2016-17. Setting a target of reaching 40% from these waste sectors by 2025 will be ineffective as they have been reached or are very close to being reached. The final action plan should set a target for the major waste sectors that helps to progress diversion, with construction and demolition perhaps being less than 40%, commercial and industrial waste being 50-60% and municipal solid waste being 50-60%.
The target to reduce waste generated in Tasmania by 5% per person by 2015 and 10% by 2030 is very unambitious and should be greatly increased. We suggest that they be at least doubled. There should also be a target to cap the total amount of waste produced by Tasmania by the waste sector.
The final action plan should acknowledge the link between carbon emissions and waste and that this industry is obligated to help to reduce carbon emissions.
The Draft Waste Action Plan states that diversion of construction and demolition waste is ‘significantly lower’ than other states. As stated previously in this submission the MRA Consulting Group’s 2017 submission to LGAT found that construction and demolition waste diversion was only 9% in Tasmania in 2012-13. This is massively below most other states and territories. South Australia has a diversion rate of close to 90%, ACT 80%, Victoria 77% and NSW 69%. This comparison should be emphasized in the final plan by inclusion of a stand-alone chapter on construction and demolition waste.
The Draft Waste Action Plan commits to a reduction in organic waste going to landfill but it should commit to a reduction in the production of organic waste as well. We note that the National Food Waste Strategy aims to halve Australia’s food waste by 2030 and this should be the goal for Tasmania.
The packaging target should be amended to prioritize waste avoidance and reduction ahead of recycling as per the waste management hierarchy. There should also be an absolute target i.e. capping the total quantity of packaging waste to be produced.
We note the absence of a target in relation to phasing out of problematic and unnecessary plastics. A measurable target should be set for Tasmania.
Moving to a circular economy: Government Priorities and Key Sectors
Note the comments above regarding the lack of a clear explanation of the circular economy concept and the key waste management principles.
The government priorities for reducing waste generation are very vague and include actions that are not clear and implementable. It is unclear who is responsible for initiating and coordinating the actions and this should be clarified in the final action plan.
The Draft Waste Action Plan states that ‘Regeneration is partly about the shift to renewables’ but then refers only to renewable energy. The final action plan should suggest other potential strategies and actions.
The Draft Waste Action Plan falsely equates power with electricity and this is very misleading. It should refer separately to electricity generation and other forms of power or energy including transport fuels such as petrol and diesel.
The Draft Waste Action Plan states that ‘there is more work to do in the areas of Sharing (reuse)’ ‘Optimising’ and ‘Looping’ but makes no suggestions for potential strategies and actions. This should be rectified in the final strategy.
Governance
Establishing roles and responsibilities is perhaps the key component of any plan, but Draft Waste Action Plan fails to do this. The Draft Waste Action Plan suggests that local government alone with be consulted regarding possible governance models but it is false to assume that local government should play such a leading role. Local government will naturally recommend a leading role for local government. The key players who must be included are the waste management industry, waste producers and the broader community. These sectors should be given equal opportunities in future consultation over possible governance approaches.
Implementation of the final action plan will require a body that provides coordination, planning, support and data to ensure the plan is being implemented, is kept up to date and brings together key stakeholders and assists them. This is especially important as the draft plan recommends numerous other specific plans and strategies that must be coordinated with the main plan.
The Waste Management Council, which was dissolved by the previous minister, was supposed to perform these functions but seemed to fail in this regard. The next strategy needs to recommend a coordinating body that has sufficient powers and capacity to drive the strategy implementation. The lessons of the past need to be learnt but it is unclear why the WMC apparently performed so badly and what needs to be done differently.
Data, Innovation Networks and Resource Recovery Targets
The actions in this section relating to data management and innovation are very vague and lack specific actions. It is unclear what an innovation and research network is and key concepts such as this need to be properly defined. The actions need to include timeframes, who is responsible and what the actions aim to achieve.
Statements such as ‘innovative approaches’ ‘arise naturally’ are unacceptable as it implies that nothing needs to be done to advance innovation.
Infrastructure Planning
This section merely proposes that an infrastructure plan be prepared. After two years of discussion with the waste management industry the Draft Waste Action Plan should at least outline the framework for the type of infrastructure required by the waste management industry. The Draft Waste Action Plan doesn’t even identify who prepares the infrastructure plan.
We note the very sensible recommendations regarding infrastructure made in the 2017 MRA Consulting Group’s report to LGAT and recommend that these be incorporated into the final waste action plan.
Support Resource Recovery across Industry
Each action identified in this section is quite positive but they are far too vague and hypothetical to make informed comments. Each action starts with words such as ‘develop’, ‘establish’, ‘support’, ‘investigate’ or ‘boost’ without stating who will do this work, whether the resource are available, what they aim to achieve and when the actions are to be delivered. It is disappointing that two critical areas, organic waste management and market development will be addressed through further studies and strategies.
Government procurement policies are a critical way to increase demand for reused or recycled products and the proposed action should be more specific in terms of what different levels of government are willing to commit to.
Education and Community Engagement
There is an unstated assumption that councils and regional waste groups are the most appropriate organizations to be undertaking waste education and community engagement. Councils have quite inconsistent approaches to information provided to the community and this function would be best left to a statewide organisation or regional groups, noting that the south currently doesn’t have a regional waste management group.
There is no mention of the benefit of education as a means of avoiding and reducing the production of waste and reducing the cost of living. In particular, encouraging people to buy goods such as clothes that are longer lasting and to reduce food wastage save them money while reducing waste.
2. State and National Policy and Regulatory settings
The final action plan needs to acknowledge the proposed changes to the Tasmania’s Environment Management and Pollution Control Act to improve management of clean fill. This proposed change to EMPCA aims in part to increase the reuse and recycling of construction and demolition waste and should be identified as a key action being proposed to improve this most under-performing waste sector.
The Draft Waste Action Plan does not raise the possibility of banning certain single use takeaway packaging which is currently being introduced by Hobart City Council.
This proposal should be acknowledged in the final action plan. Further, it should commit to actions to support the roll-out of bioplastics such as collection and composting infrastructure. There also needs to be research into the safety of composted bioplastics being used to grow edible foods as this is apparently unknown.
The Draft Waste Action Plan does not raise the possibility of banning certain materials being sent to landfill, which is disappointing as some waste types are currently banned e.g. whole car tyres. Consideration should be given to banning e-waste going to landfill to reduce the environmental and human health hazard. The Victorian government will soon introduce such an e-waste ban. Shredded tyres should also be banned from landfill which will further assist in recovery of used tyres and act as an alternative to a levy.
Stopping certain materials being sent to landfills can extend the life of landfill sites as well as encouraging recycling.
Tasmania needs a controlled waste monitoring and reporting system to ensure the higher risk wastes streams are being appropriately stored, collected and treated or disposed of.
Tasmania lacks a clear policy on the sighing, design and operation of energy from waste facilities and the state government should prioritize making policy or guidelines.
Tasmania currently misses out on the potential of waste stewardship programs, with the program for paint not yet being rolled out in Tasmania and television and computer programs lacking state government support. The state government needs to show more leadership in this area by helping councils to fund existing programs and advocating for programs active on the mainland to be extended to Tasmania.
Yours sincerely,
Peter McGlone
Director